https://www.taxtmi.com/highlights?id=97434 Validity of a tax withholding certificate under Section 197 was challenged; the court held that where factual and legal conditions remain unchanged from prior years in which nil-rate certificates were granted, the competent authority cannot substitute a 10% withholding rate. The court found prior tribunal and Supreme Court findings attributing a portion of revenue to the Indian PE and that such attribution was absorbed by distributor remuneration to be final, rejected the respondent's reliance on a subsequent demand as a basis for a higher rate, quashed the 10% certificate and directed issuance of a nil-rate certificate for AY 2026-27 within fifteen days. en-us Fri, 06 Mar 2026 08:30:57 +0530 Fri, 06 Mar 2026 08:30:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97434 Validity of a tax withholding certificate under Section 197 was challenged; the court held that where factual and legal conditions remain unchanged from prior years in which nil-rate certificates were granted, the competent authority cannot substitute a 10% withholding rate. The court found prior tribunal and Supreme Court findings attributing a portion of revenue to the Indian PE and that such attribution was absorbed by distributor remuneration to be final, rejected the respondent's reliance on a subsequent demand as a basis for a higher rate, quashed the 10% certificate and directed issuance of a nil-rate certificate for AY 2026-27 within fifteen days. Highlights Income Tax Fri, 06 Mar 2026 08:30:57 +0530 https://www.taxtmi.com/highlights?id=97434